COMMON HRSA COMPLIANCE QUESTIONS: Clinical Staffing – NPDB Queries

The HRSA Site Visit Protocol states (Clinical Staffing, Element c. question #5) that a health center should complete a “query through the NPDB for NPDB-reportable provider types”. Project Officers, reviewers, and health center leaders interpret this requirement in varied ways.

  • Some interpret this to mean that the health center must run National Practitioner Data Bank (NPDB) queries on their provider staff (Licensed Independent Practitioners or LIPs): Physicians (MDs/DOs), Dentists, PAs, or NPs, etc.
  • Others interpret this to mean that the health center must run National Practitioner Data Bank (NPDB) queries on their provider staff (LIPs) and some of their Other Licensed of Certified Practitioners (OLCPs) staff: RNs, LPNs, CMAs, RDs, or Pharmacists).
  • And still others interpret this to mean that the health center must run National Practitioner Data Bank (NPDB) queries on all of their clinical staff (LIPs and OLCPs), including those they would classify as “Other Clinical Staff”: MAs or CHWs where licensing or certification is not required, etc.

According to NPDB/HRSA, “Health Center Program grantees and look-alikes are legally required to report clinical privileges actions taken against physicians (MD/DO) and dentists. Therefore, during attestation, your health center is verifying that it has submitted all legally required reports on physicians and dentists. You may report - and are encouraged to report - clinical privileges actions taken against health care practitioners other than physicians and dentists when those clinical privileges actions are based on the practitioner’s professional competence or professional conduct that adversely affects, or could adversely affect, the health or welfare of a patient. We encourage entities to report on other practitioners so that other health centers and employers will have access to important information when making hiring, privileging, and credentialing decisions.” (https://www.npdb.hrsa.gov/communityneducation/webcasts/healthCenterAttestationWebinarQA.jsp)

Also, in the Site Visit Protocol, the Credentialing and Privileging File Review Resource states that for LIPs, the health center must provide a “copy of completed report from National Practitioner Data Bank (NPDB) query or documentation that the health center is signed up for continuous query from the NPDB (i.e., health center signs all their providers up and NPDB sends them a real-time report if anything changes in any provider’s file.)”. However, under the OLCP and “other clinical staff” column, the reference states, “The NPDB does not include information on all provider types, including some OLCPs. Therefore, this may be “N/A” for certain providers.” (Health Center Program Site Visit Protocol: Credentialing and Privileging File Review Resource, August 20, 2019, https://bphc.hrsa.gov/sites/default/files/bphc/programrequirements/pdf/candpfilereview_resource.pdf)

So, given the current ambiguity, the most conservative recommendation is to complete a query through the NPDB for NPDB-reportable provider types upon hire and on a recurring basis for all clinical staff (LIPs, OLCPs, and “Other Clinical Staff”) who are directly employed, independently contracted, or volunteers. Numerous Clinical consultants who perform HRSA Operational Site Visits have requested clarification in this area so we hope further clarity will be provided in the coming months.